Progress: Addressed, Not Adequately
DOT Relevance: 172 Subpart H
This key area involves training requirements, responsibilities, and resources for personnel involved in the infrastructure supporting commercialized hydrogen vehicle operations. The scope of this specific training area is limited to that which is or should be regulated by 49 CFR 172.700-172.704, which addresses hazardous materials training. This applies, for example, to training for personnel involved in transporting fuel to hydrogen vehicle fueling stations. It is assumed that the training referred to in this key area does not apply to other personnel working at hydrogen vehicle fueling stations and involved in tasks outside the scope addressed by DOT hazardous materials regulations (e.g., personnel involved in vehicle refueling or station maintenance).
This key area will be critical if hydrogen fuel cell vehicles are commercialized with a fuel-supply infrastructure that involves personnel delivering fuel to the stations in a fashion that is significantly different from current gasoline and diesel fuel deliveries to automotive fueling stations. The likelihood of this depends on the likelihood of future hydrogen vehicle commercialization and the type of fueling infrastructure that evolves to support the vehicles.
For example, if hydrogen vehicles are commercialized with fuel tanks that store hydrides (such as sodium borohydride) that must be recharged at a central processing plant, then this key area will be critical because new and specialized training regulations and resources will be required. In this fueling infrastructure scenario, personnel will have to transport and conduct operations with hazardous materials in a public-access environment in a fashion that is quite different from current gasoline or diesel fuel delivery.
The language of 49 CFR 172.700-172.704 regulations pertaining to hazardous material training purpose and scope, federal-state relationship, applicability and responsibility for training and testing, and training requirements may adequately apply to potential future commercialized hydrogen vehicle fueling infrastructures. However, the specific training resources, programs, responsibilities, and testing procedures are very uncertain at this time. Therefore, progress in this key area is rated as Addressed, Not Adequately.
Some training materials and programs for hydrogen vehicle operations are being developed and do exist at this time. Examples include the CaFCPs Emergency Response Guide. Other examples include various hazardous materials transportation and operations training programs provided by industrial gas and chemical companies. However, current hydrogen-vehicle-specific training does not include all possible fuel-supply infrastructures, and the industrial gas and chemical training does not generally address the special public-access-delivery issues that may apply to deliveries to public fueling stations.
It is recommended that progress toward commercialized hydrogen vehicle operations should be monitored with particular emphasis on potential hazardous materials transportation operations that may be part of the fuel supply infrastructure. The applicability and adequacy of the training regulations contained in 49 CFR 172.700-172.704 should be assessed, and the development of the required training programs and materials should be monitored. If these regulations and/or training programs are found to be inadequate, then the development of new specifically focused regulations and/or training programs should be initiated.